SNCF is a global leader in passenger transport services and one of the
largest operators of high-speed rail in the world.

According to SNCF America, Inc. President & CEO Alain Leray, “The Texas
Central Rail project has been designed around the best interest of a
single company, not what is best for Texans or the state’s rail
transportation future. If the federal government allows the Texas
Central Rail project to move forward as proposed, it would likely close
the door on the future of high-speed rail in communities like Austin,
San Antonio, Waco and Temple, while placing huge risks on the shoulders
of local, state and federal taxpayers.”

A full copy of SNCF’s America’s comments to the Draft EIS can be found HERE
and highlights are summarized below:

Modern passenger rail services can only be successful if they are
conceived and planned as networks. In a state of 28 million
people, TCR’s proposal to construct a high-speed line that is limited
to Houston and Dallas will deprive other Texas cities of high-speed
rail options. A network approach generates demand from many different
cities, while the TCR approach is dependent on ridership only on the
I-45 corridor to sustain the profitability of its proposed high-speed
rail service. If the TCR line is built, Texas will lose the
opportunity to develop a network that serves cities along the
congested I-35 corridor, as well as the critical combined ridership
from all of these cities, which would share large portions of track
infrastructure and improve the prospects of running a more financially
viable operation.

SNCF America supports a “T-Bone” network
configuration, which would provide high-speed rail access to 2.6
million more Texans (see attached diagrams). The “T-Bone” network
would serve Houston, College Station, Dallas, Fort Worth, Waco,
Temple, Georgetown, San Marcos, and San Antonio, a much more efficient
way of connecting these cities than would be possible after the
construction of the proposed TCR Dallas-Houston route. Once the
proposed TCR is constructed, an enormous “Texas Triangle” of track
covering 763 miles would be required to serve these cities, a far less
efficient and more expensive configuration than the 480 mile “T-Bone.”

Operational revenues will likely not be sufficient to cover debt
service. SNCF America is aware of only two high-speed systems in
the world that cover infrastructure amortization with the revenues
they generate. These two systems (Tokyo-to-Osaka and Paris-to-Lyon)
have low infrastructure amortization costs because they were built
approximately a half-century ago. That is not reality in today’s
environment.

No country in the world operates a fully
privately-funded high-speed rail infrastructure. Whether China,
Germany, or Morocco, government funding is required to build the
infrastructure.

Texas Central Partners has been forthcoming
about exploring “all forms of capital available to private companies
to finance debt for the project, including federal loan programs.”
While TCR has declared that its project will be 100 percent privately
funded, if loan payments fall short in the future due to underwhelming
revenue, taxpayers would ultimately be liable for loans secured under
Railroad Rehabilitation & Improvement Financing (RRIF) and/or
Transportation Infrastructure Finance and Innovation Act (TIFIA), as
cited in 1.1.2.2 of the Draft EIS.

The concept of private
financing, while seductive, is virtually impossible to achieve with
the financial debt-service burden of infrastructure that costs $45
million per mile to build.

The Draft EIS is flawed because it fails to address the comparative
advantages and disadvantages of high-speed (125-210 mph) versus higher-speed
(max 125 mph) technologies for the Dallas-Houston corridor. Instead,
it focuses on a single technology available from a single company.
High speeds can’t be accommodated on tight curves and steep slopes.
However, higher speeds can take tighter turns and can use much more of
the existing rights of ways, reducing the need to use eminent domain.
The cost of building rail lines for higher-speed trains would be $23
million per mile for two conventional electrified tracks, compared to
$45 million per mile for two high-speed tracks. Before doubling the
infrastructure costs (which could ultimately fall to taxpayers to
cover) and using excessive eminent domain powers, the FRA should take
a hard look at whether high-speed is possible, expected, or necessary
for each segment of a proposed network.

The proposed TCR line does not serve the city centers of Dallas and
Houston, compounding the financial challenges. Convenience is a
critical competitive advantage for using high-speed rail, especially
among regular business travelers, but this is not the case with the
TCR plan. By locating stations on the outskirts of cities, TCR will
have to more vigorously compete with air and road travel.

Neither
higher-speed, nor high-speed rail systems, should be expected
to be successful and profitable if they do not serve city centers of
their primary destinations or connect to established commuter train
networks serving city centers. This should be a critical consideration
of the FRA, as well as the potential environmental, economic, and
social impacts of the project’s failure to serve city centers.

TCR eliminates the opportunity for rail competition in Texas
because Japanese technology is not compatible with standards currently
used in the United States, the United Kingdom and the EU. While the
Japanese N700 Series Shinkansen is safe, comfortable and reliable,
Texas would be “marrying” Japanese technology, for better or for
worse, and closing the door to competition.

About SNCF

SNCF
is a global leader in passenger and freight transport services, with
revenue of $41.2 billion in 2017, of which one-third on international
markets. With 270,000 employees in 120 countries, SNCF draws on its
foundations in French rail and its extensive experience as an architect
of transport services. It aims to become the benchmark for mobility and
logistics solutions in France and worldwide.

About SNCF America, Inc.

SNCF America, Inc. is a U.S. based company incorporated in the state of
Delaware.